Know your customer and AML

The Anti-Money Laundering Act, 2020 (Act 1044) asks the firm to know who it acts for. The system keeps that knowledge on each party's KYC tab and tells the firm what is missing.

What the firm holds

The firm decides, per kind of party, what it must hold: for a person perhaps a GhanaCard and proof of address, for a company its registration, directors and beneficial owners. The KYC tab shows what is held and what is still missing against that rule.

• Identity documents, each with its reference, expiry and scan.
• Beneficial owners of an organisation, with percentages that cannot add up to more than the whole.
• Politically exposed person declarations.
• Source of funds for high risk and high value work.

The risk band

The system suggests a band, low, medium or high, from the kind of client, the kind of matter, the value, the jurisdiction and any PEP declaration. The compliance function confirms it with a reason. Verification is refused until what the rule requires is held.

A verified party is reviewed again after a period set by its band, three, two or one year by default. A document that expires, or a review that falls due, puts the party back on the worklist.

The worklist

Settings, Compliance, KYC worklist lists every party missing something, due for review or expired.

KYC and opening a matter

By default an incomplete KYC warns when a matter opens and leaves a banner on it. The firm can set it to block opening instead.

Internal concerns

Anyone may raise a concern about suspicious activity. Only the compliance function and the managing partner can read concerns; the person who raised one sees that it was received and nothing more, and a client never sees anything. The compliance function assesses each concern and records whether an external report was made, with its reference.